Table of Contents - June 2009
Note: In accordance with IRS Circular 230, Regulations Governing the Practice of Attorneys, Certified Public Accountants, Enrolled Agents, Enrolled Actuaries, and Appraisers before the Internal Revenue Service, the information on this website is not intended or written to be used as, and cannot be used as or considered to be a "covered opinion" or other written tax advice, and should not be relied on for the purpose of (1) avoiding tax-related penalties under the Internal Revenue Code or (2) promoting, marketing or recommending to another party any transaction or tax-related matter(s) addressed herein, for IRS audit, tax dispute or other purposes.
Bullets indicate items in the Tax Clinic department.
Accounting Methods & Periods
• IRS Continues to Challenge Deferral of Revenue from Gift Cards
• Recognizing Unbilled Revenue
• Tax Court Addresses Claim of Offset Against Deferred Payments
• To Capitalize or to Expense: How Sec. 263A Treats Royalties
Expenses
• Unit of Property for Network Assets
Foreign Income & Taxpayers
FBAR Penalties Reduced for Six Months
Gains & Losses
IRS Reverses Position on Eligibility of Intangibles for Like-Kind Exchange Treatment
• Customs Valuation: A Concern for Unsuspecting Tax Practitioners
• Sec. 1245 Recapture Rules Can Apply to Stock
Circular Like-Kind Exchange Disallowed
Gross Income
• Electric Utility Refunds Qualify for Sec. 1341 Tax Mitigation
Individuals
IRS Advises How Part Owners Should Handle $1 Million Mortgage Deduction Limit
Student Loan Forgiveness and Repayment Programs
Legislation
Legislation Extends Aviation Taxes
LLCs & LLPs
Handling LLC Member and Member Affiliate Loans and Guarantees
Partners & Partnerships
Prop. Regs. on Determining Partners’ Distributive Shares
• Allocating Liabilities Among Related Partners: Determining the Impact of IPO II
Practice Management Why and How to Conduct a Tax Practice Inspection
Tax Practice Quality Control Guide
Procedure & Administration
• IRS Announces Procedures for Tax Return Preparer Penalties
Establishing Substantial Authority for Undisclosed Tax Positions
Limitation Period for Equitable Innocent Spouse Relief Held Invalid
S Corporations
• Recent Amendment to Sec. 1374 Provides Limited Opportunity for S Corps
